Search - consideration

Whether or not a particular legal defeasance is a legal defeasance which effects novation can only be determined following consideration of all of the terms and conditions pertaining to the particular defeasance.  ...

You have offered two interpretations of CEE for our consideration: 1.      ...

Should you have a factual situation involving an actual taxpayer that you wish to have considered, you should forward all relevant facts and documentation to the appropriate district taxation office for their consideration. ...

Meeting with Finance In response to numerous queries received from Revenue Canada concerning the proposed Part 1.3 tax; Finance agreed to attend a meeting with us to discuss their intent and policy considerations inherent in the drafting of the Part 1.3 legislation. ...

., Compagny Law considerations relating to Corporate Actions and Reorganization, 1976 Conference Report, p. 235.]       ...

You have offered two interpretations of CEE for our consideration: 1. ...

As discussed with you in our telephone conversation of March 28, 1989 whether assets, i.e. goodwill and mangement contract of Opco, are considered to be used in an active business is a question of fact that requires consideration of all the circumstances of the situation before it can be determined whether or not the operations of Opco constitute an active business. ...

It also states that a payment made after December 20, 1991 that is otherwise a periodic pension payment would not be a periodic payment and thus subject to the full 25% Part XIII tax where, subject to certain exceptions, the total of all payments made under the RRIF at or before that time of the payment and in the year exceeds the greater of (a) twice the amount that would be the minimum amount under the fund for the year, and (b) 10% of the amount that would be the fair market value of the property held in connection with the fund at the beginning of the year if all property transferred in the year and before that time to the carrier of a fund as consideration under the fund had been transferred immediately before the beginning of the year and the definition of "minimum amount" in paragraph 146.3(1)(b.1) of the Income Tax Act were applicable with respect to all RRIF's. ...

Based on the foregoing, it is our view that generally a guarantee fee is not income from property but rather is income from business and should not be taken into consideration when calculating an individual's CNIL account. ...

In addition, the fair market value of the specific rights which are being assigned to the employee or shareholder in excess of the consideration, if any, which would be paid by the employee or shareholder for such rights would constitute a taxable benefit pursuant to paragraph 6(1)(a) or subsection 15(1). ...